Jul. 27, 2023 – In re Jayden M. (2nd. Dist., Div. 2, B321967)

The Court of Appeal affirms the order bypassing mother for reunification services pursuant to WIC 361.5 (b)(10) and (11). The court holds that in assessing whether a parent made a reasonable effort to address a problem from a prior dependency, the juvenile court should consider the entire time span between the earliest time a sibling or half-sibling was removed from the parent’s custody due to that problem and the dispositional hearing in the current case.